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Sub-agent couldn't be considered as internal CUP if it didn't provide services to assessee's parent company

November 6, 2019[2019] 111 381 (Mumbai)

TRANSFER PRICING: Where assessee, providing business support services, became agent of foreign based parent shipping company and former agent was appointed as sub-agent of assessee, since said sub-agency did not provide services to parent company, it could not be considered as internal CUP rather TNM method was to be applied for benchmarking said transaction

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